1. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 1 Responses to 802_11, 802_3, and Paul Nikolich on Pending 802.15.4f PAR comments November Plenary Date: 2008-11-11 Authors:

2. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 2 802.15.4 RFID PAR and 5C Comments Received from 802.11 The 802.15.4 RFID PAR & 5C are incomplete and should not be approved because: –The 5C & PAR incorrectly claim there is no existing international standard There are currently standards available for active tag technology, but none meet all the requirements identified in the PAR document. –The 5C & PAR need to include evidence that there is user demand for yet another RFID standard There are existing efforts in other standards organizations but none have the wherewithal to build a air interface protocol that 802.15.4 already addresses in a way can meet the active RFID requirements. Additionally, many of the other organizations specifically name IEEE 802.15.4 as viable and available globally to provide a standard air interface protocol for this purpose. The presence of multiple single-purpose standards clearly eliminates the opportunity for a true, globally available standard. If a true global standard is developed, then it is highly likely that it would be used in all of the industries referred to above, which in turn would mean a very large user base. –The 5C & PAR need explain what technical deficiencies of existing systems the proposed standard will address Most active tags today in the market use a simplex (one-way) transmission scheme used for the sole purpose of determining location. Some tags require the ability to provide bi-direction communications as well as ranging using ultra-low power. One active tag type not used for determining location is ISO/IEC 18000-7 (433 MHz). This tag type is used for identification but requires interrogation from a reader and does not transmit autonomously, uses a frequency not globally available, and has a limited read distance. –The 5C & PAR need to provide a better justification of technical feasibility for a unified standard that addresses the requirements of all market segments Economies of scale in the active RFID markets are not being met due to a lack of a globally available standard. Today, numerous vendors are producing active tags that meet very specific (and proprietary/non-interoperable) requirements of customers but are doing so independently. An active RFID standard will set the baseline for continued growth but gain the value that economies of scale can bring to price and production levels. –The 5C & PAR need to acknowledge the use of 802.11 in this space today and explain why a 802.15.4 based solution will be significantly better One other IEEE standard used for some active tags today is 802.11b. This type of active tag, as previously noted, is used exclusively for location determination and some (relatively little) sensing. The primary issue with using 802.11 for autonomous active RFID tags is the amount of energy required to power the tag and the short lifetime and short mean time between maintenance intervals to replace batteries. Autonomous RFID tags are absolutely expected to run for 3-5 years without a battery change. This is not possible with 802.11. Furthermore, 802.11 continues to focus on higher data rates than what is common with 802.15.4 and less on ultra-low energy consumption. Lastly, the volume of active RFID tags within a confined region using 802.11 will have a severe impact (high collision rate) on ‘non-tag’ stations on the same WiFi network.

3. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 3 802.15.4 RFID PAR and 5C Comments (2) The 802.15.4 RFID 5C & PAR incorrectly claim there is no existing international standard –The 5C asserts that there is a need for an international standard for active RFID, and the PAR asserts that is there in no international standard. Most active tags today in the market use a simplex (one-way) transmission scheme used for the sole purpose of determining location. Some tags require the ability to provide bi-direction communications as well as ranging using ultra-low power. There are no international standards that meet this capability and moreover, EPCglobal has specifically identified 802.15.4 as one clear option for active RFID tags meeting this requirement. –However, the 5C indicates that an international standard does exist, and even quotes the number of an ISO standard. One active tag type not used for determining location is ISO/IEC 18000-7 (433 MHz). This tag type is used for identification but requires interrogation from a reader and does not transmit autonomously, uses a frequency not globally available, and has a limited read distance. –There are also other quasi international standards in this space that need to be acknowledged explicitly in the PAR. The 5C and PAR need to be modified to correct this error. A “quasi-international standard” is by definition not an international standard and should not be considered. Moreover, there was no indication within the question as to which ‘quasi-standard’ should be addressed. –Is it the intention to state that there are no suitable international standards? If so, then such a statement needs justification in the PAR. Yes, there are no suitable existing standards with explanation in previous answers.

4. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 4 802.15.4 RFID PAR and 5C Comments (3) The 802.15.4 RFID 5C & PAR need to include evidence that there is user demand for yet another RFID standard. –The 5C and PAR assert that active RFID tags have not been successful so far because there are too many options available, which has reduced interoperability and economies of scale. That may be true Active tags exist and have been successful in very limite quanties and for very specific functions, hence eliminating any economies of scale as noted. –However, the PAR & 5C do not explain how the development of yet another standard will solve this problem, particularly in a context where 802.15.4 does not have much scale today, certainly in comparison with, say, 802.11. Today 802.15.4 is the most prevalent air interface standard for tags that require long battery life with limited maintenance. –The 5C and PAR need to be modified to include evidence that there is user demand for yet another standard. There is considerable demand for a globally available standard that includes the identified requirements: –Ultra-low energy consumption (low duty cycle) –Low PHY transmitter power –Both one-way and two-way communications (simplex and duplex transmission) –High tag density (large tag population of hundreds of thousands) –Reader to tag and tag to tag (meshing) communication (unicast) –One to many communication (multicast) –Authentication –Sensor integration –Accurate location determination capability –Minimum of 100m read range –Global availability (with our without licensing) –Capable of avoiding, or operating in the presence of interference from other devices operating within the Active RFID’s frequency band of operation

5. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 5 802.15.4 RFID PAR and 5C Comments (4) The 802.15.4 RFID 5C & PAR need to explain what technical deficiencies of the existing systems the proposed standard will address. –One reason that would justify a new standard is that all the existing mechanisms are missing functionality from a technical perspective –If this is not the case, why not just submit one of the existing mechanisms to EPCGlobal, IEEE or ISO? –However, the PAR & 5C do not address the issue of whether existing systems are technically deficient –The PAR & 5C need to be modified to explain what technical deficiencies of existing systems the proposed standard will address There is a need for a common international standard for an active tag RFID system. Active RFID tag types must be capable of : –Ultra-low energy consumption (low duty cycle) –Low PHY transmitter power –Both one-way and two-way communications (simplex and duplex transmission) –High tag density (large tag population of hundreds of thousands) –Reader to tag and tag to tag (meshing) communication (unicast) –One to many communication (multicast) –Authentication –Sensor integration –Accurate location determination capability –Minimum of 100m read range –Global availability (with our without licensing) –Capable of avoiding, or operating in the presence of interference from other devices operating within the Active RFID’s frequency band of operation

6. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 6 802.15.4 RFID PAR and 5C Comments (5) The 802.15.4 RFID 5C & PAR need to provide a better justification of feasibility for a unified standard that addresses the requirements of all market segments –One reason that the active RFID market is segmented today is that each market segment has different requirements –However, the 5C and PAR assume that a unified standard can achieve the goals of every market segment –It incorrectly bases technical feasibility for the unified standard on an argument that each of the existing standards are technically feasible –It is possible that the market requirements for the various segments are contradictory. –The 5C and PAR need to demonstrate technical feasibility for the unified standard, not just a subset Each of these bullets has been specifically addressed the previous four (4) sets of questions preceding this one.

7. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 7 802.15.4 RFID PAR and 5C Comments (6) The 802.15.4 RFID 5C & PAR need to acknowledge the use of 802.11 in this space today and explain why a 802.15.4 based solution will be significantly better –It is asserted in the 5C that the proposed active RFID functionality is not addressed in any existing 802 standard. –However, there is a growing opinion among some in the industry that 802.11 based systems could dominate this space There are already several start-ups that are showing Wi-Fi based sensor chips with very low power and cost – and of course with Wi-Fi you don’t require a separate infrastructure. Today 802.15.4 is the most prevalent air interface standard for tags that require long battery life with limited maintenance –The PAR & 5C needs to be modified to recognize the existing use of 802.11 in the active tag space, and explain why 802.15.4 offers significant benefits over 802.11. The answer should account for the fact that 802.11 based solutions exist today, whereas 802.15.4 based solutions may not exist for some years (5 years?) One other IEEE standard used for some active tags today is 802.11b. This type of active tag, as previously noted, is used exclusively for location determination and some (relatively little) sensing. The primary issue with using 802.11 for autonomous active RFID tags is the amount of energy required to power the tag and the short lifetime and short mean time between maintenance intervals to replace batteries. Autonomous RFID tags are absolutely expected to run for 3-5 years without a battery change. This is not possible with 802.11. Furthermore, 802.11 continues to focus on higher data rates than what is common with 802.15.4 and less on ultra-low energy consumption. Lastly, a growing volume of active RFID tags within a confined region using 802.11 will have a severe impact (high collision rate) on ‘non-tag’ stations on the same WiFi network.

8. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 8 Comments from 802.3 1. I'm aware of P1902.1, an RFID project nearing Sponsor ballot. It isn't addressed in PAR 7.1, and it seems to me to have significant overlap in multiple functional areas: low data rate, high density of RFID tags, etc. it would be appropriate to address the differences (which I'm sure there are) when requesting another RFID project. There is a need for a common international standard for an active tag RFID system radically different than what is proposed in P1902.1. Active RFID tag types must be capable of : Ultra-low energy consumption (low duty cycle) Low PHY transmitter power Both one-way and two-way communications (simplex and duplex transmission) High tag density (large tag population of hundreds of thousands) Reader to tag and tag to tag (meshing) communication (unicast) One to many communication (multicast) Authentication Sensor integration Accurate location determination capability Minimum of 100m read range Global availability (with our without licensing) Capable of avoiding, or operating in the presence of interference from other devices operating within the Active RFID’s frequency band of operation

9. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 9 Comments from 802.3 2. This project does not seem to be within the scope of LMSC: "The scope of the LMSC is to develop and maintain networking standards and recommended practices for local, metropolitan, and other area networks, using an open and accredited process, and to enable and advocate them on a global basis." Please address why this project should be done within LMSC and how it falls within the scope of this Sponsor committee. There is currently not an international standard for active RFID networks. The purpose of 802.15.4f is to develop one. An active RFID standard requires first and foremost a two-way communication capability further requiring a globally available standard defining the PHY and MAC. Hence it is appropriate that it falls into the 802 wireless PAN standards group ensuring compliance with the 802 LAN/MAN architecture, 802 security, and overall 802 network management described in 802.1 3. Some would assert that the most important characteristic unifying LMSC standards is the commonality provided by adherence to the 802 Overview and Architecture. One of the unifying features of the Overview and Architecture is that 802 LANs are bridgeable and that one network type may be substituted for another within the architecture. The 802 address space is insufficient to address the requirement of RFID. The cursory Five Criteria response to this issue is insufficient to understand how this technology fits within the 802 architecture. The use of active RFID tags will never meet the potential prevalence of passive RFID tags. Passive tags are meant to identify all items/product and in some respects may replace a barcode. Active tags are more expensive by nature and are used to identify assets that have a known depreciated value. Active tags will also be used for sensing, location determination, and creating adhoc mesh networks, and will in essence become an asset that must me managed within an organization. Passive tags are generally used one time and are thrown away (again, identifying an item). Active tags have much more value and will be reused over and over within the enterprise or between multiple enterprises.

10. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 10 Comments from 802.3 4. The project documents do not describe if the project will address security and privacy concerns related to RFID technologies (something EPCglobal had some struggles with). This is defined in the 802.15.4 standard which allows for the optional use of encryption 5. Please include within the project documents a commitment to include a PICS proforma in the initial version of the standard. Yes, we commit to provide a PICS proforma in the initial version of the standard

11. doc.: IEEE 802.15-08-0803-00-rfid Submission November 2008 Mike McInnis, George CavageSlide 11 Comments from Paul Nikolich P802.15.4f: I recognize the proposed PHY is for Active RFID applications, but is there a more generic way to describe the functional characteristics of the PHY (max energy consumption, data rate range, frame size, frequency band, bandwidth occupied, max distance for a given error rate, environmental specs (temp, shock, vibration, etc.), high availability, etc. ) that allows it to be decoupled from the Active-RFID application? A robust set of functional requirements may give the project a tighter focus, allow the work to be completed more quickly and find a broader application set that only Active-RFID. Active RFID applications require both a globally available standard as well as support a higher degree of functionality. As previously stated, the following are required capabilities: –Ultra-low energy consumption (low duty cycle) –Low PHY transmitter power –Both one-way and two-way communications (simplex and duplex transmission) –High tag density (large tag population of hundreds of thousands) –Reader to tag and tag to tag (meshing) communication (unicast) –One to many communication (multicast) –Authentication –Sensor integration –Accurate location determination capability –Minimum of 100m read range –Global availability (with our without licensing) –Capable of avoiding, or operating in the presence of interference from other devices operating within the Active RFID’s frequency band of operation